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Home My WebLink About04-5833 BURTON NEIL & ASSOCIATES, P.C. By: Jay H. Pressman, Esquire Identification No. 38800 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff AMERICAN HOME ASSURANCE Parsippany New Jersey, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04 - SPJ3 CLUlLc..,~ R. HART ENTERPRISES, INe. 1200 Rossmoyne Road, Mechanicsburg P A 17055 Defendant : CIVIL ACTION - LAW COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, P A 17013 Telephone No. 717-249-3166 or 800-990-9108 58386 BURTON NEIL & ASSOCIATES, P.C. BY: Jay H. Pressman, Esquire Identification No. 38800 1060 Andrew Drive, Suite 170 West Chester, P A 19380 610-696-2120 ATTORNEY FOR: Plaintiff AMERICAN HOME ASSURANCE Parsippany, New Jersey Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. D4 - SP.J3 (]lOLL '--r~ R. HART ENTERPRISES, INC. 1200 Rossmoyne Road Mechanicsburg, Pennsylvania Defendant : CIVIL ACTION - LAW Complaint 1. The plaintiff is American Home Assurance with place of business located in Parsippany New Jersey. 2. The defendant R. Hart Enterprises, Inc. is a business corporation with place of business located at 1200 Rossmoyne Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. At all times material and relevant hereto, plaintiff was engaged in the insurance business and was authorized to conduct insurance business within the Commonwealth of Pennsylvania. 4. At the instance and request of the defendant, plaintiff issued insurance coverage to the defendant as follows: Policy Number WC 536606600 Coverage Period 8/20/02 to 8/20/03 5. The insurance coverage provided by plaintiffto the defendant was in full force and effect during the coverage period. 6. Plaintiff sent defendant a statement reflecting the balance due plaintiff for the insurance premium for the insurance coverage, which statements defendant received without protest. A copy of the statement is attached hereto, made a part hereof and is marked Exhibit A. 7. Although demand was made by plaintiff upon defendant to pay the sum of$5,763.00, the defendant failed and refused to pay all or any part thereof. 8. Plaintiff is entitled to interest at 6% per annum from 30 days after the statement date. Wherefore, plaintiff American Home Assurance demands judgment against defendant R. Hart Enterprises, Inc. in the sum $5,763.00, together with interest at 6% per annum from 30 days after statement date and the costs of this action. BURTON NEIL & ASSOCIATES, P.C. BY:~~ ay . Pressman, Esquire t rney for Plaintiff ..=- . . Gteup. Inc:. AMERICAN INTERNATIONAL COMPANIES speclelty w....... ~ Greup INVOICE ....... ~ 0000:;11'" For IiIing '-*'.. C8II: lIOO-MJ.ml E-.II www.~~.e- CURGIlER __ 21411&1 ..... to: -. u.. IIIOIJ2OOI ,..,of' PrllcIuM: "117' It HART .1~'ln, IHC. UOO R088MOYNE WAY ~PA'7OI6 VIACIDMP, IIC. 301 flORAL VALE avo yAflt:U.Y, ''''1017 ,nt'D"i' '1J1Q1W ,..,. rttI1/OW Pr*Y AMOUNT ....... ON 'MI tfCVOICI + '. + AMOUNT ... + . ",la.ClO t 'c'Jl8I2GOS . 111,1".00 ........00 '717.00 "1.00 ".783.00 .........., 1M _In ....,,.. ........, VOW' CUINftt policy .. IIeIUllieot . ,,~~ AGcOWIt IummIry 1tlrGuIIt TOTAL JIQUCY PMMUM TOTAl PAYMENT RECEIVED TO DAte TOTAL flEl'UND8 PlDI/U.ED TO DATE CUIIR8fT IALAHCE .,' I ,I "''','' , -..I, ,\"'" ~ .....-~..~ '.1,."" .. " . I . ) I r . ~,'> t:' .' l"'.t."t ~}. ~'I.!r~.)C")1;;t ' ~,' ~ 1; 1.,1-' r _. ~ _ . ,.,,' . . I ".' \ ,'. ,..... ~ ~q",,;^.~~. ',<. t . , ~ MY~ COUfOIIIBOW 'MTllYOWI PAYMENT .... DO 1101' 11M>> A PHOTOCCPf GllOn""1 1,.,... we: 0111,.1011110' tI,7A.OC) D33D3D303DDOO~I~S~~OOI300D1020031eO~OODDDDD051~30020000a o Q41CK..... 'tOUR ADD_ HAl QtAHGB) AM) COMUTf fORM ON IlEYER8E 8IOL o 011<* HIM FYOUR PClUCY .'1HANClD AND AO"MI UalMMlOlA11LY a.LIP TO: fLHARI'!II.I..___-'.IIC. UOO ..,." 'Ow WAY ~Ml7OH Hr \:-.....lHT8lNATIONAL CCMPANB ".0. 80X 3UDl. . ~PA '1210-1O'4 Arch,. Cop, ___ COPY .- EXHIBIT .(\ Y\ . Verification I, ---:J;t~ f)' ! cr~,/Ct14/ verify that I am t/ f/ -1 W/Y-'ldYctC--/ (Name of authorized representative) (Title or Position) p(~ ~~ for American In.tc..ilJdt.iuui11 C\nupanies the within Plaintiff and am authorized to make this verification on its behalf. The foregoing complaint is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: I \ q \tft ;s&~mro representative) ~~ --- GV ~ n ~ iN r ~ o ~ r Y- "', (") c~ ,,' ~ C:"c~.) <. ..> __c- -'"',~ " ) 'Il'......:. CD ~~ 0) en o -n --I ."1'. fl1 ~: r-- -nCI"1 C:J 'J (~) I, J; ,~~} '.c) ; in 9 SHERIFF'S RETURN - REGULAR CASE NO: 2004-05833 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN HOME ASSURANCE VS R HART ENTERPRISES INC SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon R HART ENTERPRISES INC the DEFENDANT , at 2022:00 HOURS, on the 7th day of December, 2004 at 5154 KYLOCK ROAD MECHANICSBURG, PA 17055 by handing to R HART a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.88 .00 10.00 .00 36.88 So Answers: ~~~c~<~~ R. Thomas Kline 12/08/2004 BURTON NEIL Sworn and Subscribed to before me this "J F- day of ()-::,/ dlJ05 A.D. ~I. 0 111'~J ~ rothonotary / By: ~- k irI Deputy Sheriff j I AMERICAN HOME ASSURANCE 300 Interpace Parkway, Bldg. C, 1" Floor PO Box 409 Parsippany, NJ 07054-0409 IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 04-5833-CV R. HART ENTERPRISES, INC. 5154 Kylock Road Mechanicsburg P A 17055 Defendant : CIVIL ACTION - LAW Praecipe for Default Judgmeut To the Prothonotary: Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal Interest TOTAL $5,763.00 $403.30 $6,166.30 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities, I verifY that: I. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201 (b)(I)(A) of the Servicemembers Civil Relief Act of2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER P . elV.p.236 BY: SOCIATES, P.C. Pro Prothonotary Jay . Pressman, Esquire Att rney for Plaintiff . . #38800 1060 Andrew Drive, Suite 170 W. Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 58386 ...: AMERICAN INTERNATIONAL Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-5833-CV R. HART ENTERPRISES, INC. Defendant : CIVIL ACTION - LAW Notice ofIntention to File Praecipe for Defanlt Judgment TO: R. Hart Enterprises, Inc. 1200 Rossmoyne Road Mechanicsburg P A 17055 DATE OF NOTICE: December 29,2004 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or obligations to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 BURTON NEIL & ASSOCIATES, P .C. BY: Jay H. Pressman, Esquire Attorney for Plaintiff Identification No. 38800 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 , , ~: BURTON NEIL & ASSOCIATES, P.C. BY: Jay H. Pressman, Esquire Identification No. 38800 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 ATTORNEY FOR: Plaintiff AMERICAN HOME ASSURANCE Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.04-5833-CV R. HART ENTERPRISES, INC. Defendant : CIVIL ACTION - LAW RULE OF CIVIL PROCEDURE NO. 236 (REVISED) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on rrz ';J/l c~ 7 ~M. \' ( Prothonotary ~rh1l~2J((J2/?fl~(- Deputy [fyou have any questions concerning the above, please contact: Jay H. Pressman, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, P A 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector. G -p () ..(q. 't -:-D '1- ~ \) ,-, ?J .;:::..'J C) F w ~';::) .-n - C;::,.f' .~A "" ...r:. ::t':. :;: ..,-. -;;::,;' plf..c-' - W :.;:'J ~ ..t:: ~ ~ ~O\'!\ ~ . '.)- -~., u t ~ ':~~:\(), -n r",.>~;), ~ :J,~ '?D C.': ) ~ ..-\ -c~. C:) .l..l ,- -'^-~ ~ ~ ~ -... PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. ~ 3103 to 3149 AMERICAN HOME ASSURANCE Plaintiff ; IN THE COURT OF COMMON PLEAS VS. ; CUMBERLAND COUNTY, PENNSYL V ANJA R. HART ENTERPRISES, INC. Defendant( s) : NO. 04-5833-CV ; CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER I. Directed to the Sheriff of Cumberland County, Pennsylvania 2. 3. against R. HART ENTERPRISES. INC. and against , Defendant(s) , Gamishee(s) 4. and index this writ ( a) against (b) against Defendant(s) Garnishee( s) as a lis pendens against the real property of the defendant( s) in the name of the Gamishee( s) as follows: (specifically describe property) Levy on all property of the defendant at: 5154 Kylock Road, Mechanicsburg P A 17055 5. Amount Due Interest from 317/05 Total *Plus writ costs Dated: May 11,2005 $6,166.30 $66.96 $6,233.26* Jay H. Pressman, Esquire Attorney for Plaintiff NOTE: Under paragraph I when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing afthe execution in the county of issuance is desired as authorized by Rule 3 J04(a). When the writ issued to another county indexing is required as of course in that county, See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104( c). The finn of Burton Neil & Associates, P.C. is attempting to collect a debt. - :... V p, ~ 'b ~ ~ L - () L,.. B l.J ~ pD \l'l - ~ ~ V\ --- GJ ~1n ..p::..~ V1 C) () ()o r-0, r\J ~ .{q" (~ w- ~ ~-:G0\J~ ""V Vj C) ""t ~ C> "\> () <> Q '"'V ()' I I \ ~-J ~ C'- ~ - ~ ' - + \ - ~ -~ ~ #f: - :-) () 5 -n cf' ~ ;:." -"''- - -' 9 0) <,..:' WRIT OF EXECUTION and/or ATTACHMENT h COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5833 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due AMERICAN HOME ASSURANCE, Plaintiff (s) From R. HART ENTERPRISES, INC., 5154 KYLOCK ROAD, MECHANICSBURG, PA 17055 (I) You are directed to levy upon the property ofthe defendant (sland to sell LEVY ON ALL PROPERTY OF THE DEFENDANT AT 5154 KYLOCK ROAD, MECHANICSBURG, PA 17055 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNlSHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himiher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $6,166.30 Interest FROM 317105 - $66.96 L.L. $.50 Atty's Comm % Atty Paid $118.88 Plaintiff Paid Due Prothy $1.00 Other Costs Date: MAY 17, 2005 CURTIS R. LONG (Seal) Prothonotary ~ ~dA'O/l.o _P. (/?/?A~- Deputy REQUESTING PARTY: Name JAY H. PRESSMAN, ESQUIRE Address: BURTON NEIL & ASSOCIATES, P.e. 1060 ANDREW DRIVE, SUITE 170 WEST CHESTER. P A 19380 Attorney for: PLAINTIFF Teleplione: 610-696-2120 Supreme Court ID No. 38800 Thomas Kline, Sheriff, 'Yho being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee Postage TOTAL $ Advance Costs: Sheriffs Costs: 190.23 190.23 $ 000.00 18.00 123.33 .50 1.00 7.40 20.00 20.00 Refunded to Atty on 190.23 So Answers; ~t?..' . ,/ ",' r .. ~~~,~,_."^? R. Thomas Kline, S:heriff / (\ ~ MJ-~ ~<j:)(J~( k-fuaudia A. Brewbaker ,... ..., '-<:' Sworn and Subscribed to before me 0-, '"" 'e.; This '1"':: day of7l.t,~ 2005^"D t!U!~1 ( Proth ~~, ,,-"... " ''''~;''''') '" ~,., -... ... //'';;--'" ~ ~~~ I .5'6 J<...5' a' '; ~. /10?<lb/ WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5833 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due AMERICAN HOME ASSURANCE, Plaintiff (s) From R. HART ENTERPRISES, INC., 5154 KYLOCK ROAD, MECHANICSBURG, P A 17055 (I) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ALL PROPERTY OF THE DEFENDANT AT 5154 KYLOCK ROAD, MECHANICSBURG, P A 17055 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof: (3) If property of the defendant( s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee. you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $6,166.30 Interest FROM 3/7/05 - $66.96 L.L. $.50 Atty's Corom % Ally Paid $118.88 Plaintiff Paid Due Prothy $1.00 Other Costs Date: MAY 17, 2005 CURTIS R. LONG (Seal) prothon:2 p ~ <l,!y: '/( rJ/)-€. / . ,'I(/2/r~ Deputy REQUESTING PARTY: Name JAY H. PRESSMAN, ESQUIRE Address: BURTON NEIL & ASSOCIATES, P.C. t060 ANDREW DRIVE, SUITE 170 WEST CHESTER, PA 19380 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court 1D No. 38800 ~J:..) (Ii C.'-; BURTON NEIL & ASSOCIATES, P.C. By Jay H. Pressman, Esquire Identification No. 38800 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff AMERICAN HOME ASSURANCE COMPANY : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 04-5833-CV R. HART ENTERPRISES, INC. Defendant : CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Mark the judgment Satisfied on payment of your costs only. BURTON NEIL & ASSOCIATES, P.C. 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